This regulatory change is unnecessary and duplicative in that a patient's Pupillary Distance ("PD"), if measured, is automatically a part of their medical record. As such a patient has a right under the Code of Virginia and Board Regulations to their own medical record, including their PD. Furthermore current practice allows other licensed individuals other than an Optometrist to measure a patient's PD. The proposed regulation would require an Optometrist to measure the patients PD rather than authorizing them to delegate this duty to a licensed Optician or entity. Thus the practice of requiring an Optometrist to measure a patient's PD rather than allowing other licensed individuals, such as an Optician or an Ophthalmologists, would be discriminatory in nature.